CUNA Comment Letter
NCUA's Proposed Rule on the Privacy Act (Part 792)
August 11, 2000
Ms. Becky Baker
Secretary
National Credit Union Administration Board
1775 Duke Street
Alexandria, VA 22314-3428
RE: NCUA's Proposed Rule on the Privacy Act (Part 792)
Dear Ms. Baker:
The Credit Union National Association (CUNA) appreciates the opportunity to comment on NCUA's proposed rule on the Privacy Act. CUNA represents more than 90 percent of our nation's 10,500 state and federal credit unions.
The proposed rule will incorporate the following changes to NCUA's rules regarding the Privacy Act:
- NCUA will respond to requests for information covered under the Privacy Act within 20 working days, with a possible 10- day extension. For an adverse decision, an appeal must be filed within 30 days.
- Copying fees for Privacy Act records will be 5 cents per copy, the same as outlined in the Freedom of Information Act (FOIA) fee schedule.
- Any requirement that an individual produce a notarized statement affirming his or her identity will be eliminated. An unsworn declaration, under penalty of perjury, will now be sufficient.
- NCUA will ensure that an individual may receive his or her non-exempt medical records, although special procedures will be in place to minimize potential harm that may result from the release.
CUNA supports the proposed rule. Coordinating the procedures for public disclosure between the Privacy Act and the FOIA will be helpful for credit unions, as well as the general public. We specifically support the reduction of the copying fees from 25 cents to 5 cents. Credit unions and others will appreciate this reduction and encourage additional cost reductions whenever possible.
Thank you for the opportunity to comment on NCUA's proposed rule on the Privacy Act. If Board members or agency staff have questions about our comments, please give me a call at 202-218-7795.
Sincerely,
Jeffrey Bloch
Assistant General Counsel
